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ESTATE OF REED v. COMMISSIONER

Docket No. 11745.

8 T.C.M. 303 (1949)

Estate of Morton W. Reed, Deceased, Grace R. Stratton, Executrix v. Commissioner.

United States Tax Court.

Entered March 29, 1949.

Attorney(s) appearing for the Case

D. Nelson Adams, Esq., 15 Broad St., New York, N. Y., for the petitioner. Ellyne E. Strickland, Esq., for the respondent.

Memorandum Opinion

MURDOCK, Judge:

The Commissioner determined a deficiency of $83,717.84 in estate tax. The petitioner contends that the Commissioner erred in including the value of an inter vivos trust in the gross estate under section 811 (c). The stipulated facts show that the trust gave the income for life to the decedent and expressly created a possibility of reverter of the trust corpus in the estate of the decedent. The decedent was in reality the...

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